Consultation response
Autumn 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.
Issue 1c (i) - Improving consistency and understanding of the type of limits offered at the account level
Proposals
We consulted on the following proposals:
- a requirement that financial limits must be applied at the account level. This was an elevation of one part of the current RTS implementation guidance that states “limits may be implemented per customer, per account, or other means”
- implementation guidance that operators could also continue to offer financial limits at the product or channel level. This was a minor amendment to current implementation guidance as a result of the proposal for “limits applied at the account level” to become a requirement
- implementation guidance that operators should clearly communicate to customers how product and channel limits work. This was a minor amendment to current implementation guidance
- new implementation guidance that operators should determine whether customers holding multiple accounts wish to apply limits across all accounts held within the parent company
- new implementation guidance that operators should inform customers about how limits set across multiple timeframes work, if chosen by the customer.
These proposals were developed with the intention of improving consistency across the industry in how limits are offered, with the intention of also increasing customer understanding of how limits work in practice.
As noted, we proposed that operators should inform customers about how limits set across multiple timeframes work, for example, when a customer sets both a daily and a monthly limit on their account. The issue of the actual duration or period for financial limits to apply will be considered as part of a supplementary consultation and this response is concerned only with the communication to customers about how limits will work.
Consultation questions
To what extent do you agree with the proposal that limits must be applied at the account level?
To what extent do you agree with the proposal that gambling licensees can also continue to offer financial limits at the product or channel level in addition to account level limits?
To what extent do you agree with the proposal that gambling licensees should clearly communicate to customers how product/channel limits work?
To what extent do you agree with the proposal that the gambling licensees should determine whether customers holding multiple accounts wish to apply limits across all accounts held?
To what extent do you agree with the proposal that gambling licensees should inform customers about how limits set across simultaneous timeframes work, when a customer chooses to set multiple limits?
Respondents’ views
In relation to limits at the account level, the majority of respondents supported this proposal. Respondents commented that customers found it easier to understand their spending at the account level rather than spread across different activities or channels. Some suggested limits apply across multiple brands within a parent company, or all accounts held across multiple operators.
In relation to proposed implementation guidance that operators could continue to offer financial limits at the product or channel level, respondents’ comments were generally around the need for transparency, ensuring consumer understanding and risks around confusion and friction in the customer journey. The majority of respondents supported this proposal and the proposal for associated guidance that operators should clearly communicate how any product and channel limits work.
In relation to the proposal for implementation guidance that operators should determine whether customers holding multiple accounts wish to apply limits across all accounts held within a parent company, support for this proposal was mixed, with comments including:
- the approach could deliver additional player protection through cross-operator limits being applied across brands within the parent company, but this would not go beyond to other brands or operators
- the approach would create unfairness and inconsistency between multiple accounts within a parent company and those outside
- potential confusion for consumers, which could lead to more opting out
- contradiction with the rationale for limits to apply at the account level.
In relation to implementation guidance that operators should inform customers about how limits set across multiple timeframes work, if chosen by the customer, some respondents provided examples of scenarios where it was possible to hit a limit then continue to play or deposit due to technicalities of how multiple limits could be applied. The majority of respondents supported this proposal.
Our position
We welcome the support from respondents who agreed with the proposed requirement that limits must be applied at the account level, regardless of whether operators also offer limits across individual products or channels.
We agree with respondents who noted the need for clear communication about how product and channel limits would work, and the need to minimise friction in the customer journey so customers are not inadvertently discouraged from setting limits.
To be clear, we did not propose that all licensees must offer limits at product or channel level, we proposed that licensees could retain the option of offering them. We note that most respondents supported this proposal and agreed with our intention to improve consistency while not restricting or removing customer choice where it currently exists.
This consultation did not attempt to address messaging or the quality and content of safer gambling information. We are aware of work being led by Department of Health and Social Care (DHSC) to develop public health-led messaging in relation to gambling, as well as ongoing research to determine appropriate messaging designed to address issues around information for players. We will continue to monitor this and will revisit this position should evidence emerge to inform further changes to regulatory requirements or implementation guidance.
We aimed to extend the transparency we expect around how different types of limits work across different products and channels to that of different time frames, to reduce the risk of confusion or misunderstanding by customers about how limits set across different time frames work.
This specific question related to the introduction of implementation guidance that operators should communicate how that works, rather than the requirement itself. For the avoidance of doubt, the Gambling Commission’s view is that when limits are set across simultaneous timeframes, staking or depositing (depending on the type of limit) must stop when the most restrictive limit is reached. For example, if a customer sets a £20 per day deposit limit, and a £100 per week deposit limit, the customer should be prevented from depositing once the £100 is hit, even though there may be ‘unspent days’ in the 7-day period.
While we acknowledge that there may be consumer benefits to licensees exploring the option of offering limits which apply across multiple brands within a parent company, we do not intend to progress this at the current time.
The aim of this proposal was to explore the potential of additional player protections by reducing friction associated with applying limits across other accounts held by a customer with other brands within the parent company.
We have carefully considered comments from all respondents against the policy intentions set out in the consultation, including bringing more consistency to the customer experience of pre-commitment tools, and reducing frictions and barriers to making use of these tools for those who wish to. We conclude that:
- the proposal could add friction to the process for setting one account limit which may have unintended consequences of customers choosing to opt out of setting a limit or abandoning the process
- elsewhere in the consultation, we have proposed that limits should apply at the account level, and any messaging around application of limits to other accounts may be confusing for consumers who are more likely to see their relationship as being with the brand, rather than the parent company or group.
Our decision not to proceed with this proposal does not impact on or override requirements for licensees to be able to identify multiple accounts held by customers as currently required under Licence Conditions and Codes of Practice (LCCP) 3.9.1 – Identification of individual customers, or the requirement for licensees to use customer account and activity data such as spend and use of gambling management tools to monitor account activity for the purposes of identifying risk of harm under LCCP 3.4.3 - Customer interaction.
We are proceeding with the proposed changes to the status and wording of existing provisions, but not proceeding to introduce the proposed new implementation guidance on determining whether customers with more than one account with the ‘parent company’ would want to apply limits to each account.
Final wording
This requirement will come into force on 31 October 2025.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12B
As a minimum, limits must be applied at the account level.
RTS implementation guidance 12B
In addition to account-level limits, limits could be implemented across individual products or channels. Where gambling licensees offer the facility to set limits for individual products or channels it should be made clear to customers using the facility whether those limits apply at the account or product/channel level. For example, where a limit has been set for a specific game, a customer should not be misled into assuming that the limit automatically applies to other products.
Where a customer sets simultaneous time frames, gambling licensees should provide clear information on how the interaction between those limits works.
Last updated: 4 February 2025
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